Package deal

The close of the consultation on extended producer responsibility for packaging is a good time to take stock. Dominique Barry, strategic account manager at Valpak, explains why we need change, what to expect, and how we can bring about the best outcomes from the new system.

When the new extended producer responsibility (EPR) for packaging waste legislation arrives in 2023, the system will be radically transformed. As well as taking on responsibility for the full cost of collection and recycling, brands and importers will shoulder the financial burden of litter management, and commercial and industrial packaging.

Once the four UK governments announce final policy, the countdown will be on. In the meantime, it’s worth reminding ourselves what this ambitious legislation is looking to achieve – and how obligated businesses will prepare, both to meet the environmental aims and to mitigate the huge cost increases heading their way.

When the first Packaging Waste Regulations were introduced 24 years ago, the UK recycling rate for packaging waste was less than 30 per cent. Since then, investment in infrastructure and collection systems have made a real difference, and, in 2019, we achieved 61 per cent.

The UK’s recycling success story, however, does not reflect the situation in which we find ourselves today, and the goal for the next quarter of a century will push us further and faster.

The overall aim of EPR is to drive the design of more environmentally friendly packaging. In current terms, ‘environmentally friendly’ means recyclable. Tackling design to eliminate less recyclable packaging will reduce the need to source valuable virgin resources. It is also expected to increase the recycling rate to 78 per cent and bring about a carbon reduction of 4.38 million tonnes between 2023 and 2032.

These changes don’t come cheap. Packaging recovery note funding represents only around seven per cent of the cost associated with the management of packaging waste in the UK. Under the new system, producers will be charged 100 per cent of the cost – rising from an estimated £230m in 2020 to £2.7bn.

Aside from the level of funding, the greatest change in the upcoming system will be the introduction of modulated fees

Aside from the level of funding, the greatest change in the upcoming system will be the introduction of modulated fees. The aim of modulation is to nudge producers into designing more environmentally friendly packaging; the use of recyclable materials will result in a lower cost, with difficult-to-recycle packaging incurring a higher fee.

The data challenge for obligated businesses will be daunting, at least in the short term. Even those packaging products that qualify for lower fees will need to demonstrate their eligibility; many items are complex, made from a number of different materials and elements.

A pot of jelly, for example, typically includes five materials – paper, aluminium and three polymer types. While these elements are all widely recycled in the UK, other packaging products are less EPR-friendly. Many types of plastic are not currently recyclable, and obligated businesses will be reliant on supply-chain data to make informed choices.

Some countries have already implemented greater scrutiny of recyclability. In Spain, for example, producers must categorise plastics into nine polymer types, with lower fees charged for more easily recycled polymers, such as polyethylene terephthalate (PET) and high-density polyethylene (HDPE).

To help UK packaging producers to prepare, Valpak’s recent PackFlow EPR report used data from our Environmental Product Information Centre (EPIC) database to model the types of EPR scenarios proposed under modulation. The most feasible option bands materials according to recyclability. Under this method, the cost of EPR for plastics ranged from £129.56 per tonne for ‘green’ polymers that are collected at kerbside and likely to be recycled, to £310.12 for those classified as ‘red’ – not collected at kerbside and unlikely to be recycled.

While the exact requirements under modulation will not become clear until policy is announced, this analysis will help businesses to plan ahead. We are also extending our data-collection service to address many of the expected requirements for EPR and the Plastic Packaging Tax, and working one to one with producers to help them prepare. So far, 207 businesses have signed up for one-to-one clinics, with more than 1,000 attending EPR and Plastic Tax webinars.

Addressing design

Widespread redesign is a challenging prospect but, with the right preparation, we can move to a world where the impact of packaging is less damaging to the environment. Many have already started the process. For example, the voluntary Plastics Pact agreement has resulted in a 40 per cent reduction in the use of unnecessary plastic and recycling increasing by 107,000 tonnes.

Until now, the financial burden has been spread throughout the supply chain; under the new system, it will be passed to those with the greatest opportunity to make change – manufacturers, brands and importers.

The extent to which consumer prices will change remains largely unknown, but Valpak’s PackFlow EPR project has sought to provide a rough estimate.

For those hoping to make positive change, performing life-cycle analysis on a case-by-case basis is crucial. Sometimes, it can throw up unexpected results. For example, while Defra figures1 show that plastic has a higher carbon impact per tonne than paper and cardboard, it is also very light. This means that, often, plastic will be a lower-carbon option for a particular product.

In one of our consultancy projects for a brand, however, we looked at alternative options for plastic wrapping. In this case, cardboard offered a lower-carbon impact, because of the weight of the cardboard and the energy needs of the equipment used to seal the plastic wrapping onto the packs.

Where redesign is not possible, it may be necessary to change the landscape. For example, eight high-street brands have come together through the National Cup Recycling Scheme to offer a £70-per-tonne incentive to waste collectors to make UK cup recycling a reality. Since the launch of the initiative, 159 million cups have been recycled, and we can expect to see more innovative solutions in the future.

While the detail of the EPR will be decided in due course, we can be confident that it will drive wholesale packaging redesign. The solution is to collect the relevant data and identify the greatest areas of risk.

Starting the journey to become EPR-ready will safeguard the packaging industry, while building a more Earth-friendly system for future generations.


  1. Defra, Greenhouse gas reporting: conversion factors 2021

The feature first appeared in the July August issue of Circular. 

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